Strategic Environmental Assessment (2007-2011) Consultation Review
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Water Supply Project – Eastern and Midlands Region Water Supply Options Working Paper Appendix F Strategic Environmental Assessment (2007-2011) Consultation Review June 2015 Revision A01 Contents 1 Introduction 1 2 Stakeholder feedback 2 2.1 Background 2 2.2 Review of submissions 2 3 Additional Options 3 3.1 Further Clarification 9 4 General Concerns 10 5 Post Adoption of The Plan 13 5.1 Stakeholder Briefings 13 5.2 An Bord Pleanála Stakeholder Engagements 14 6 Conclusion 17 150525WSP1_AppendixF(SEAConsultationReview)_A01.doc 150525WSP1_AppendixF(SEAConsultationReview)_A01.doc 1 Introduction This report outlines the Strategic Environmental Assessment Consultation Review carried out as part of Phase 2 of the option appraisal methodology. Table 1-A Options Appraisal Methodology 150525WSP1_AppendixF(SEAConsultationReview)_A01.doc 1 2 Stakeholder feedback 2.1 Background Formal public consultation under SEA Phase 2, in respect of the ten water supply options which were contained in the 2008 Draft Plan, took place from November 2008 to February 2009. Extensive feedback was received from stakeholders and the general public during the consultation periods. This feedback was collated and analysed in the SEA Phase 2 Public Consultation Summary Report (2011). Further consultations were held post adoption of the Plan and publication of the SEA Statement (2010). This was a stakeholder briefing exercise advising stakeholders of the preferred option and consisted of a series of minuted meetings. Details of the presentations, minutes of meetings and questions & answers arising from the presentations / briefings were collated and analysed in the Stakeholder Briefing Report. 2.2 Review of submissions Reflecting the consultation process outlined above, this review of submissions is presented as three sections: • Review of submissions that identify additional options thought worthy of consideration. • Review of submissions that include general comments on the ten water supply options contained in the draft Plan. • Review of comments received on the adopted Plan that remain applicable to the planning stage. The review is undertaken to consider if: • Submissions received through the SEA process were considered and appropriately addressed. • Submissions received post adoption of the Plan are captured and addressed appropriately in this planning stage. 150525WSP1_AppendixF(SEAConsultationReview)_A01.doc 2 3 Additional Options A number of alternative options arose for consideration in feedback from consultation on the draft plan. They are as listed below: • Water Conservation • Water Abstraction below Ardnacrusha • Lough Erne • Changes to Operating regime at Pollaphuca • Lough Dan/ Lough Tay • Freshwater Lake in Dublin Bay • Liffey Catchment • Water Recycling/ Reuse • Groundwater under Bogs • Canals • Quarries • Wicklow Mountain Storage • Groundwater + Shannon • River Brosna • River Boyne • Lisheen Mine • Relocation of Water Intensive Industry • Local Storage • Large Wetland National Park • Flooding/Large Scale rainwater harvesting. The submissions outlining these options are summarised in Table 3-A alongside the corresponding documented response provided during the SEA stage. 150525WSP1_AppendixF(SEAConsultationReview)_A01.doc 3 Ref Option Key points of proposal Response to issues provided during the No. SEA stage. 1 Water - T. O'Mahony highlighted that the EPA are promoting water As part of the planning application & approval Conservation conservation within the region and are looking for a firm process, there will be an onus on the Dublin commitment to water conservation in both the DRWSA and Region to demonstrate that it is maximising the the Shannon i.e. the footprint of the project (EPA) sustainable production of its existing resources -Increases in demand could be met with the introduction of and implementing leakage reduction measures / water conservation measures (rainwater harvesting, water consumption reductions. Without such metering, hose pipe ban).A comprehensive programme of measures in place it is unlikely that an water conservation requires assessment as an alternative unconditional planning approval will be in its own right. (Birdwatch Ireland/ DCC SPC/ DLRCC/ achieved. A planning approval from An Bord Etc.) Pleanála may well be conditional on the - Carrying out an EIA on three options is fair and achievement of specified leakage or renewal reasonable to the stakeholders. A decision has to be made targets and water consumption reductions which by DEHLG to move forward. There really needs to be a would have to be met into the future, even with a credible conservation plan (comment from T O’Mahony, new source being available (Stakeholder EPA). Briefing Report, 2011). 2 Water Below Why not abstract the water below Ardnacrusha where the Water below Ardnacrusha is tidal and is not a Ardnacrusha water enters the sea? (ShIRBD Advisory Council) suitable technical location. An additional 50 km of pipeline is required which will increase capital and operating costs (€150m). Water can be abstracted in a variable manner from north Lough Derg (including Storage) and achieve greater sustainability / flexibility & robustness through the use of storage at significantly reduced cost (Public Consultation Report, p. A73). 3 Lough Erne Was any consideration given to abstracting water from L Sufficient sustainable options exist within the Erne? (Border, Midland and Western Regional Authority) Republic’s own jurisdiction with the result that the additional complexity and additional costs of a cross border option would not be justifiable. Lough Erne is further from the Dublin Region than the preferred recommended option from Lough Derg (Public Consultation Report, p. A7). 4 Changes to ESB is not in favour of a change in the operating regime at Only relevant to Liffey Barrow option which is Operating regime Poulaphuca (ESB) not recommended (Public Consultation Report, at Poulaphuca p. A29). 150525WSP1_AppendixF(SEAConsultationReview)_A01.doc 4 Ref Option Key points of proposal Response to issues provided during the No. SEA stage. 5 Lough Dan/ In relation to new sources of water for Dublin please let me It was considered in Year 2000 Review of 1996 Lough Tay know if the catchment area of the Lough Dan/Lough Tay Strategic Water Study (Public Consultation area of County Wicklow has been considered. This area is Report, p. A42). very close to the Vartry waterworks in Roundwood. A study of this area was done before the Vartry works was commissioned; I have seen this report on the web but failed to locate recently. (Hugh Lee) 6 Freshwater Lake Vision for Dublin Bay Study by DCC proposes to create Noted. in Dublin Bay freshwater lake in Dublin Bay with a potential as a water resource for the city, possibly requiring a degree of desalination - should investigate but accept it’s a very long shot. (Warren Whitney) 7 Liffey Catchment To what extent has the impact of future abstraction from the Proposed future abstractions from the Liffey (at Liffey catchment been assessed?(EPA) Leixlip) were assessed separately by Tobins Consultants. Tobins and Fingal CoCo modelled abstraction and secured an abstraction licence. The proposed abstractions from the Liffey at Poulaphuca and Leixlip represent the maximum modelled sustainable capacity of the Liffey based on a wide range of climatic conditions (Public Consultation Report, p. A18). 8 Water Recycling/ Need stringent standards for recycled water in place before Accepted. Reuse recycling water for non-potable use in Ireland. (James Fenwick) Groundwater In relation to the proposed Storage facility in Bord na Mona Plan does not include use of groundwater 9 under Bogs cutaway bogs - Are there water reserves under these bogs (Public Consultation Report, p. A19). that could be useful as reserves in their own right. (EPA) 10 Canals Are canals an option? (NTCC) Not sufficient carrying capacity (Public Consultation Report, p. A42). 11 Quarries Bog Storage proposals - could consideration be given to They were considered but are not as suitable as former Quarries in Huntstown / Belgard? (DCC CPC) the cutaway bog given the scale of requirements (Public Consultation Report, p. A14). 150525WSP1_AppendixF(SEAConsultationReview)_A01.doc 5 Ref Option Key points of proposal Response to issues provided during the No. SEA stage. 12 Wicklow Mountain Why has water from Wicklow mountains not been Abstractions from Poulaphuca and Roundwood Storage considered for storage? (Roscommon coco) are reaching their sustainable limits (Public - Build 20 or so small scale reservoirs in the Dublin / Consultation Report, p. A69). Wicklow mountains. Each reservoir would drain rainfall from 3 to 5 km2 of hillside, the combined total of water would be enough to meet the additional water needs of the GDA without serious negative impact! (Sinn Fein) Personal letter sent as response to Sinn Feins submission. 13 Groundwater + To what extent has the conjunctive use of groundwater and Groundwater sources which are of relatively Shannon? surface water been explored as an integrated option with small volume in the Dublin Region will continue one of the Shannon options? (EPA) to be developed for localised use where they are technically and economically feasible. The abstraction of supplies from a new source will supplement existing groundwater (and surface water) sources. A separate report on groundwater was prepared which recommended this approach. It is available on the project website (Public Consultation Report, p. A19). 14 River Brosna Did you ever consider taking